FTC “Click-To-Cancel” Rule Goes Into Effect May 14
On May 14, 2025, the bulk of the requirements of the Federal Trade Commission’s Negative Option Rule, also known as the “click-to-cancel” rule, goes into effect. The rule imposes obligations related to disclosure, informed consent, simple cancellation, and more.
While the rule has faced court challenges, the FTC can continue to pursue deceptive and unfair subscription practices under multiple other acts, and several state laws impose additional requirements beyond those enforced by the FTC.
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Notice
Before proceeding, please note: If you are not a current client of Perkins Coie, please do not include any information in this e-mail that you or someone else considers to be of a confidential or secret nature. Perkins Coie has no duty to keep confidential any of the information you provide. Neither the transmission nor receipt of your information is considered a request for legal advice, securing or retaining a lawyer. An attorney-client relationship with Perkins Coie or any lawyer at Perkins Coie is not established until and unless Perkins Coie agrees to such a relationship as memorialized in a separate writing.
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Consumer Protection Review helps businesses that market and sell to consumers navigate federal and state legal issues related to advertising, privacy, promotions, products liability, government investigations, unfair competition, class actions and general consumer protection.